ML032230340
| ML032230340 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 07/07/2003 |
| From: | Bhatty O TXU Electric |
| To: | Jaffe D NRC/NRR/DLPM |
| References | |
| Download: ML032230340 (10) | |
Text
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Subject:
Re: Code Relief - B-2 Creation Date: 717/03 7:18AM From: <obaidb@txu.com>
Created By: obaidb@txu.com Recipients nrc.gov owf4_po.0WFN_DO DHJ (David Jaffe)
Post Office Route owf4_po.oWFN_DO nrc.gov Files Size Date & Time MESSAGE 949 07/07/03 07:18AM B-2 Rev I.doc 2886656 B-2 Rev 1.pdf 936130 Mime.822 5234264 Options Expiration Date: None Priority: Standard Reply Requested: No Return Notification: None Concealed
Subject:
No Security: Standard
David Jaffe - Re: Code Relief - B-2 .Bel From: <obaidbitxu.com>
To: 'David Jaffe' <DHJ@nrc.gov>
Date: 7/7/03 7:21AM
Subject:
Re: Code Relief - B-2 Ok here it is ...please send me an e-mail that you got it..... Thanks It is not formatted I was going to let the Reg Affairs folks to that.
(See attached file: B-2 Rev 1.doc)(See attached file: B-2 Rev 1.pdf)
Obaid Bhatty obaidb~txu.com (254) 897-5839 Confidentiality Notice: This email message, Including any attachments, contains or may contain confidential information intended only for the addressee. If you are not an intended recipient of this message, be advised that any reading, dissemination, forwarding, printing, copying or other use of this message or Its attachments is strictly prohibited. If you have received this message in error, please notify the sender immediately by reply message and delete this email message and any attachments from your system.
to TXX-03XXX Page 1 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
-INSERVICE INSPECTION IMPRACTICALITY-I. System/Component for Which Relief is Requested:
Relief is requested for the following Class 1 piping welds in the Reactor Coolant System (Pressurizer Relief), Category B-J, Item B9.21, 1986 Edition with no Addenda of ASME Section XI:
Weld No. TBX-1-4502-12 Weld No. TBX-1-4502-28
- 11. Code Requirement from Which Relief is Requested:
1986 Edition with no Addenda of ASME Section XI for Category B-J, Item B9.21 requires that these category BJ welds which are less than 4 NPS be examined as depicted in Figure IWB-2500-8, via the surface examination method.
However, on February 15, 2001, TXU Energy had requested and was granted an approval for application of an alternative risk-informed inservice inspection (RI-ISI) program for ASME B&PVC Class I and 2 piping (refer to TAC NOS. MB 1201 and MB 1202). Via the aforementioned request TXU Energy informed the NRC staff that for Category B-J welds it will perform volumetric examination (UT) rather than the Code required surface examination.
M. Impracticality of Compliance:
The Final Rule (67FR60520) requires that if access is available, the weld shall be scanned in each of the four directions (parallel and perpendicular to the weld) where required.
Coverage credit may be taken for single side exams for ferritic piping. However, for austenitic piping, a procedure must be qualified with flaws on the inaccessible side of the weld. There are currently no qualified single side examination procedures that demonstrate equivalency to two-sided examination procedures on austenitic piping welds.
Current technology is not capable of reliably detecting or sizing flaws on the far side of an austenitic weld for configurations common to US nuclear applications.
The Performance Demonstrative Initiative (PDI) Program conforms to the Final Rule regarding single side access for piping. PDI Performance Demonstration Qualification Summary (PDQS) certificates for austenitic piping list the limitation that single side examination is performed on a best effort basis. The best effort qualification is provided in place of a complete single side qualification to demonstrate that the examiners qualification and the subsequent weld examination is based on application of the best available technology.
Attachment I to TXX-03XXX Page 2 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
-INSERVICE INSPECTION IMPRACTICALITY-When the examination area is limited to one side of an austenitic weld, examination coverage does not comply with 10 CFR 50.55a(b)(2)(xv)(A) and proficiency demonstrations do not comply with 10 CFR 50.55a(b)(2)(xv)(B) and full coverage credit may not be claimed.
Pursuant to the requirements of 10 CFR 50.55a(g)(5)(iii), relief is requested from performing the required examination as required by 10 CFR 50.55a(b)(2)(xv)(A).
IV. Burden Caused by Compliance:
Imposition of the Code Requirements would require significant system redesign, modifications, and an increase in personnel radiation exposure.
V. Proposed Alternative and Basis for Use:
The best available techniques, as qualified through the Performance Demonstrative Initiative for Supplement 2 (67FR60520) with demonstrated best effort for single side examination, were used from the accessible side of the weld.
These two welds were the only welds identified in the line segments per the RI-ISI Program which met the considerations for system design, the risk analysis, previous examinations, and NDE accessibility.
Therefore, TXU Energy believes that the examination performed provides adequate confidence that there are no matters of concern regarding the structural integrity of the subject welds. No changes are expected in the overall level of plant safety. TXU Energy will perform a surface examination along with the volumetric examination as specified by the ASME Section XI for these welds during the next upcoming outage ( or within this second interval for CPSES Unit 1).
Granting of this relief request will not have an impact on plant quality or safety and will not adversely impact the health and safety of the public.
to TXX-03XXX Page 3 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
-INSERVICE INSPECTION I1WRACTICALITY-VI. Duration of Proposed Alternative:
This relief is requested for the Comanche Peak Steam Electric Station Unit I second interval.
Attachment I to TXX-03XXX Page 4 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
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Attachment I to TXX-03XXX Page 5 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
-INSERVICE INSPECTION IMPRACTICALITY-to TXX-03XXX Page 6 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
-INSERVICE INSPECTION IMPRACTICALITY-
Attachment I to TXX-03XXX Page 7 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
-INSERVICE INSPECTION IMPRACTICALITY-I to TXX-03XXX Page 8 of 7 TXU GENERATION COMPANY LP COMANCHE PEAK STEAM ELECTRIC STATION UNIT 1 FIRST TEN-YEAR INTERVAL ISI RELIEF REQUEST NO. B-2 PROPOSED ALTERNATIVE IN ACCORDANCE WITH 10 CFR 50.55a(g)(5)(iii)
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